Searching the MEGA file in LEXIS reveals that "chutzpah" (sometimes also spelled "chutzpa," "hutzpah," or "hutzpa" has appeared in 112 reported cases. Curiously, all but eleven of them have been filed since 1980. There are two possible explanations for this. One is that during the last thirteen years there has been a dramatic increase in the actual amount of chutzpah in the United States -- or at least in the U.S. legal system. This explanation seems possible, but unlikely. The more likely explanation is that Yiddish is quickly supplanting Latin as the spice in American legal argot.